I have just published a guide on PEPs screening requirements around the world and would like to know if anybody has any feedback on it? https://complyadvantage.com/blog/politically-exposed-persons-peps-screening-requirements-around-the-world/

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  • Great work Loona! 

  • Hi Loona, Thanks for sharing. I just read article "Gatekeepers asleep on the job" from Transparency International. I copied here for your reading: "

    Reporting of major corruption scandals usually puts the high-profile kleptocrats front and centre, and rightly so. But, more often than not, the criminal and corrupt couldn’t launder their ill-gotten gains without a variety of professional services, including those of accountants, notaries, real estate agents and bankers.  

    These professions are subject to specific anti-money laundering obligations, and are meant to be the first line of defence protecting the global financial system against dirty money. 

    However, when they engage in wilful, complicit or negligent conduct, as illustrated in numerous cases, they earn another nickname: professional enablers of money-laundering

    The latest investigation into the business dealings of a politically connected family from Azerbaijan adds to the long list of examples where intermediaries appear to have helped obscure the origins of the sus....

    A lack of due diligence and reporting of suspicious transactions by professionals in Spain and the United Kingdom, in particular, seem to have helped the family in question make investments in luxurious real estate and legitimate businesses, despite major red flags. 

    Authorities in the countries involved, including in the United Kingdom, should take note of the new evidence and thoroughly investigate whether the professional intermediaries conducted the necessary checks. There should also be stronger anti-money laundering supervision and tougher sanctions for the professional enablers who open the gates of the financial system to kleptocrats."

    A couple of comments for you to consider add more in the guide: 

    1. AML/CFT needs to be controlled closely with anti-bribery and corruption laws and internal policies. Why? even though a country and a bank has a robust law/policy for AML/CFT but if dirty money is placed in the hands of a corrupt professional service employee (banker!), then the dirty fund is still laundered successfully. 

    2. Don't narrow AML/CFT in a local law perspective. It should be regulated in a multinational and international context since the nature of dirty fund is going through around. Also, if local law is not available, the internal policies and procedures must be in place to govern it. For example, a regional/international bank should develop a strong AML/CFT program itself to prevent/detect/respond/correct the laundering money transactions by tightening the due diligence process to screen PEP and their relatives, provide training of anti-bribery and AML/CFT for bankers how to prevent and detect the fraudulent/ML transactions, deploy the tools and technology to detect suspected transactions, etc.

    3. Definition of PEP is varied from country to country. Therefore, the search will based on this specific definition. For example, some jurisdictions define "if someone works for a company where government owns more than 51% of state, s(h)e is PEP."

    4. The search for PEP should be linked to OFAC to help eliminate the sanctions currently imposed by the US. 

    https://www.treasury.gov/resource-center/sanctions/programs/pages/p...

    5. Maybe you consider put PEP requirement of each country in an appendix for reference. In the body text, just write the guide how to screen and detect PEP and how it links to other laws and internal rules to help prevent AML/CFT. 

    Hope this helps.

    Thu

  •  Interesting information. I was not familiar with PEP requirements but appreciated the information. I expect it will be useful. 

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